Justia Utah Supreme Court Opinion Summaries

These cases arose from the marriage dissolution of Charles Dahl and Kim Dahl. Kim appealed the Divorce action, alleging several claims of error, and also brought a separate action against certain defendants seeking a share of the assets of the Dahl Family Irrevocable Trust, which she claimed were marital property. The Supreme Court consolidated the two cases and remanded for further proceedings because the Trust should have been joined as a party to the Divorce action. The Court further held (1) as to the Trust, Utah law applies, the Trust is revocable as a matter of law, and Kim is entitled to withdraw her share of the marital property she contributed to the Trust as a settlor; and (2) in the Divorce action, the district court judge was not biased against Kim, the district court did not abuse its discretion in its evidentiary rulings or in declining to award Kim alimony, the judgment pertaining to the division of the marital property is affirmed in part and reversed and remanded in part, the district court did not abuse its discretion when it awarded Charles sole legal and physical custody of the parties’ children, and the court did not err in not ordering Charles to pay Kim’s attorney fees. View "Dahl v. Dahl" on Justia Law

Defendant entered a conditional guilty plea to five charges of sexual exploitation of a minor. The charges arose from the discovery of child pornography on Defendant’s laptop computer. Defendant appealed, challenging several of the district court’s pretrial rulings, many of them related to the propriety of law enforcement’s use of the Wyoming Toolkit, a computer program and database used to identify child pornography shared over the Internet with peer-to-peer (P2P) file sharing networks. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress the evidence of child pornography found on Defendant’s computer, as the government’s use of the Wyoming Toolkit to identify child pornography in files shared on a P2P network is not a search; (2) the district court did not abuse its discretion in denying Defendant’s motion to compel discovery of the Wyoming Toolkit; (3) the classifications created by Utah’s sexual exploitation of a minor statute are constitutional, and Defendant lacked standing to challenge the constitutionality of the statute’s purported disparate treatment of prosecutors and criminal defense attorneys; and (4) the district court did not abuse its discretion in denying Defendant’s motion in limine to exclude expert testimony related to the Wyoming Toolkit. View "State v. Roberts" on Justia Law

Anadarko Petroleum Corporation, which acquired Kerr-McGee Oil & Gas Onshore L.P. in 2006, operated oil and gas wells from 2008 to 2011 and filed severance tax returns during this period. The severance tax rate an owner of oil and gas interests must pay depends on the fair market value of the owner’s interest. At issue in this case was how the value of such an interest is to be calculated. In 2010, the Auditing Division of the Utah State Tax Commission issued notices to Anadarko and Kerr-McGee (collectively Anadarko) informing Anadarko of a deficiency in its 2009 severance tax and assessing additional taxes and interest, and informing Kerr-McGee that its claimed 2009 refund was being reduced. Anadarko filed a petition for determination with the Commission. At issue before the Commission was whether the Auditing Division had applied the correct tax rate. The Commission granted summary judgment for the Auditing Division. The Supreme Court reversed, holding that the Commission improperly disallowed deductions Anadarko made for tax-exempt federal, state, and Indian tribe royalty interests under the severance tax statute. Remanded. View "Anadarko Petroleum Corp. v. Utah State Tax Comm’n" on Justia Law

Employees and others founded Nuriche, LLC, a now-defunct limited liability company formed in Nevada and registered to do business in Utah. After being terminated, Employees filed this complaint alleging that Nuriche and members of its board of managers (Managers) breached their agreement to pay Employees a certain amount of compensation in annual salaries and benefits and violated the Utah Payment of Wages Act (UPWA) by failing to pay past-due wages following Employees’ termination. The district court granted Managers’ motion for summary judgment, ruling that the UPWA does not extend wage liability to individual managers. The Supreme Court affirmed, holding (1) the question of Managers’ liability for unpaid wages is governed by Utah law; and (2) Managers could not be held personally liable for the unpaid wages claimed by Employees under the UPWA because Managers did not personally employ Employees but instead were acting as agents of Nuriche. View "Heaps v. Nuriche, LLC" on Justia Law

Cottage Capital, LLC brought this action to enforce a guaranty agreement against Red Ledges Land Development. The district court dismissed the enforcement action with prejudice, concluding that the enforcement action was precluded as a compulsory counterclaim because it arose out of the same transaction or occurrence as a previously filed declaratory judgment action between the parties, and there could be no waiver of the preclusive effect of Utah R. Civ. P. 13(a). The Supreme Court reversed, holding that Rule 13(a) was not implicated in this case because (1) Rule 13(a) does not extend to a counterclaim that has not yet matured at the time of a civil proceeding; and (2) Cottage Capital’s enforcement claim had not matured at the time of the earlier proceedings between the parties, and therefore, this claim was not precluded. Remanded. View "Cottage Capital, LLC v. Red Ledges Land Dev." on Justia Law

Defendants provided services for individuals with mental and physical disabilities. Some of homes run by Defendants and occupied by disabled individuals were in residential neighborhoods. A.R., a minor child, was sexually abused by one of Defendants’ employees at one of those homes. Plaintiff filed this action against Defendants, alleging negligence in the hiring, training, and supervision of Defendants’ employees. Defendants moved for summary judgment, which the district court denied. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in holding that Defendants owed a duty to A.R. to exercise reasonable care in the hiring, training, and supervision of their employees; (2) did not err in determining that Plaintiffs had no obligation to designate an expert witness to establish a standard of care; and (3) erred in concluding that Defendants were not entitled to apportion liability to their employee under the comparative fault provisions of Utah Code 78B-5-818, as the fault to be apportioned under the statute is not limited to negligence but extends to intentional torts. View "Graves v. North Eastern Servs., Inc." on Justia Law

2 Ton Plumbing, LLC recorded a notice of mechanics’ lien against a lot in a development (Lot 30). Gregory and Kendra Thorgaard later purchased Lot 30 and executed a trust deed in favor of Washington Federal. Thereafter, 2 Ton recorded amended notices of mechanics’ lien against Lot 30 and filed a lien foreclosure claim against the Thorgaards and Washington Federal. Washington Federal, meanwhile, recorded its notice of release of lien and substitution of alternate security purporting to release 2 Ton’s original notice of lien. The district court ultimately entered judgment against Lot 30, which included principal and fees and costs. The Supreme Court reversed, holding (1) 2 Ton’s amended notices of lien were invalid because they included attorney fees and costs in the value of the mechanics’ lien, but 2 Ton’s original notice of lien remained valid; (2) the Thorgaards’ notice of release of lien and substitution of alternate security complied with the statutory requirements, and therefore, the district court erred in refusing to release Lot 30 from the lien; but (3) because the Thorgaards stipulated to the accuracy of the original lien claim, 2 Ton was entitled to recover its costs and a reasonable attorney fees award. Remanded. View "2 Ton Plumbing, LLC v. Thorgaard" on Justia Law

After a night of heavy drinking at a party hosted by Travis Izatt, Neely Creager picked up Izatt’s loaded handgun and accidentally shot herself in the head. The shot killed her. Creager’s estate filed this negligence action against Izatt, alleging general negligence, negligent entrustment, and premises liability. The district court granted summary judgment for Izatt, reasoning that he owed no duty to Creager. The Supreme Court reversed, holding that gun owners have a duty in tort to exercise reasonable care in supplying their guns to intoxicated individuals, but the gun owners will not necessarily be liable for damages when those individuals injure themselves because the intoxicated individual’s negligence will likely exceed that of the gun owner as a matter of comparative negligence. View "Herland v. Izatt" on Justia Law

Vickie Warrant filed a personal injury suit against Defendants seeking damages due to her exposure to asbestos, which she claimed caused her mesothelioma. After receiving a jury verdict in her favor in the personal injury lawsuit, Warren died. Thereafter, Micah Riggs, the personal representative of Warren’s estate, filed a wrongful death and survival suit on behalf of Warren’s children that arose out of the same injury and was against the same defendants. Defendants moved to dismiss the wrongful death claim, asserting that Warren’s personal injury trial and judgment precluded the wrongful death motion. The district court denied the motion. The Supreme Court affirmed, holding that a prior personal injury suit does not bar a related wrongful death claim brought by the decedent’s heirs or personal representative. View "Riggs v. Georgia-Pacific LLC" on Justia Law

After a jury trial, Defendant was convicted of murder, aggravated robbery, and unlawful distribution of a controlled substance. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion when it admitted Y-STR DNA evidence linking Defendant to the murder weapon; (2) the trial court did not err when it refused to admit the entire transcript or video of Defendant’s second police interview after a State witness testified to portions of the interview at trial; (3) defense counsel did not render ineffective assistance in his cross-examination of one of the detectives who conducted the second interview; (4) the trial court did not err when it admitted an officer’s testimony about the frequency of drug-related crimes; (5) the State did not engage in prosecutorial misconduct during closing argument; (6) the evidence was sufficient to sustain convictions for murder and aggravated robbery; and (7) Defendant failed to demonstrate cumulative error that undermined confidence in the verdict. View "State v. Jones" on Justia Law